Background
K.B. was taken into DCFS custody in May 2024 after the State alleged that her home environment exposed her to domestic violence. Her father, Artavian C., was incarcerated in Florida when the case began. After his release in March 2025, the circuit court found he needed stable housing and employment, parenting services, and a relationship with K.B. through visitation before she could be placed in his care.
The State later sought termination, alleging that Father failed to maintain reasonable interest, concern, or responsibility for K.B.; failed to make reasonable efforts; and failed to make reasonable progress. Father participated in virtual visits and two in-person visits, but did not complete the only required service—a parenting class—despite opportunities to enroll or re-enroll. K.B. lived throughout the case with her maternal grandmother and half-sister; the grandmother was willing to adopt her.
The Court’s Holding
The appellate court affirmed. The evidence supported the finding that Father failed to maintain a reasonable degree of interest, concern, or responsibility for K.B.’s welfare. Although incarceration limited his opportunities, he did not send K.B. letters, cards, or gifts while incarcerated; after release, his virtual contact was limited, he attended only two in-person visits, and he did not complete parenting classes despite multiple opportunities.
That single statutory ground was sufficient to uphold the unfitness finding, so the court did not need to address the other alleged grounds. The court also held that termination was in K.B.’s best interests: she was safe and bonded in her grandmother’s home with her half-sister, the grandmother met her needs and sought to adopt, and both CYFS and CASA recommended termination.
Key Takeaways
- A single proven statutory ground of parental unfitness supports termination proceedings.
- Incarceration does not excuse a parent from making reasonable efforts to maintain contact and demonstrate concern for a child.
- At the best-interests stage, a child’s need for stable, permanent placement outweighs the parent’s interest in preserving the relationship.
Why It Matters
The decision illustrates how limited visitation and failure to complete an available, required service can support an unfitness finding even when a parent has some contact with the child and has obtained employment and housing. It also underscores the weight courts give to a child’s established bond with a relative caregiver willing to provide permanency through adoption.